The opinion of the court was delivered by: Judge Susan Illston
STIPULATION AND [PROPOSED] ORDER MODIFYING THE COURT'S SCHEDULING ORDER
This stipulation is made between Plaintiff DAPHNE P. RAND, by and through DEBRA J. DOLCH, as Conservator of the Person and Estate of DAPHNE P. RAND, Conservatee, ("Plaintiff") and Defendant American National Insurance Company ("ANICO" or "Defendant"), by and through their respective counsel of records, with respect to the following facts:
WHEREAS, the Court's Civil Pretrial Minute Order dated November 13, 2009 (Docket No. 78) sets forth the current scheduling order.
WHEREAS, the parties stipulated to a one week extension of time for ANICO to respond to the Court's February 9, 2010 Discovery Order concerning contact information for absent class 6 members.
WHEREAS, the parties are still conducting discovery and believe that the current scheduling order should be modified to allow for completion of discovery, resolution of any discovery disputes and any other matters;
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and among the parties, through their undersigned counsel, that the parties request a revised schedule as follows:
Current Date Proposed Date
Hearing on Motion for Class Certification June 9, 2010 September 1, 2010
Motion due May 5, 2010 June 24, 2010
Opposition due May 19, 2010 August 9, 2010
Reply due May 26, 2010 August 23, 2010
The parties agree to vacate the expert designation and rebuttal expert designation deadlines as well as the expert discovery cut-off. Instead, Plaintiff will designate experts concurrently with the filing of her motion for class certification and Defendant will ...